Supreme Court of the United States
Kevin C. Rotkiske v. Paul Klemm
December 10, 2019589 U.S. 8
Summary
Justice Thomas delivered the opinion of the Court, holding that, absent an applicable equitable doctrine, the FDCPA’s one-year limitations period begins when the alleged violation occurs, not when it is discovered. The statute’s unambiguous language forecloses importing a general discovery rule. Rotkiske could not rely on a distinct, fraud-specific equitable discovery rule because he had not preserved that argument before the Third Circuit or raised it in his certiorari petition. The Court affirmed without deciding whether equitable doctrines are available under the statute or whether Rotkiske’s claim would qualify. No separate opinions appear in the supplied text.
Holding
- When the FDCPA’s one-year limitations period begins to run.. Absent the application of an equitable doctrine, the limitations period begins when the alleged FDCPA violation occurs, not when the violation is discovered.
- Whether Rotkiske could obtain relief under a fraud-specific equitable discovery rule.. Rotkiske could not rely on that doctrine because he failed to preserve the issue before the Third Circuit and failed to raise it in his petition for certiorari.
Docket No. 18-328